# I**1S~~::::;;i2l** Barbara Twigg 01/30/2002 02:29 PM

Barbara Twigg 12/19/0104:15 PM

Dear Dishwasher Stakeholders: 

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To: Brenda Edwards-Jones/EE/DOE@DOE cc: Subject: New report on dishwasher consumer use-- and DOE request for informal comments

To: Timothy-Bernadowski@VAPOWER.com, JCockbur@NRCAN.GC.CA, Melhc@essential.org, Dan_Barzel@ccnotes.ccity.com,

cc: HCarter@Energy.commerce.state.nc.us, Natascha/castro@NIST.gov, Don.MDasher@BGE.com, rdupont@amp.com, gfoley@aham.org, glakepe@cldc.howard.edu, teckman@nwppc.org, Tim_feldman@NEMA.org, charlfcs@eei.org, dgoldstein@nrdc.org, JHardin@aarp.org, mhewett@mncee.org, bhiggens@pmihome.org, mhoffman@ceeformt.org, w.holmes@awwa.org, bkkalish@apga.org, tleland@ari.org, mmartin@energy.state.ca.us, Steven_nadel@aceee.org, eosann@aceee.org, mkrebs@il.net, jmattingly@gamanet.org, wMorris@aham.org, nemtzow@ase.org, bprindle@ase.org, Casamuels@mintz.com, mike_scott@homedepot.com, pat.stanton@state.ma.us, stevercm@eei.org, empainc@aol.com, douglas.smith@ferc.fed.us, charles.m.stephens@state.or.us, jwilson@energy.state.ca.us, loggias@csa.ca, hnewsome@ftc.gov, MichaeLc_thompson@email.whirlpool.com. nunlca@consumer.org, connma@consumer.org, Edward Poliock/EE/DOE@DOE, Qonnie Laughlin/EE/DOE@DOE, Michael McCabe/EE/DOE@DOE, bowman.j@adlittle.com, Regina Washington/EE/DOE@DOE, Carl Adams/EE/DOE@DOE, Eugene Margolis@HQMAIL@HQDOE, Francine Pinto@HQMAIL@HQDOE, rfoster@cee1.org Subject: New report on dishwasher consumer use-- and DOE request for informal comments

The Department of Energy would like to inform you that having published a limited final rule for dishwashers on December 18, 2001, we are now focusing on developing a new test procedure for soil-sensing models. Attached is a report completed by Arthur D. Little (in two formats) evaluating available survey data on consumer dishwasher use and behavior, and a short summary ofthe kind of soil-based test procedure that we are considering for sOil-sensing models. Conventional dishwashers will still be tested using clean dishes. We plan to draft a Notice of Proposed Rulemaking by the end ofJanuary 2002 and hold a formal public workshop sometime next spring. However, we would very much like to have stakeholder reaction to our preliminary concept on an informal basis, as we continue to shape our proposal and decide on appropriate test values. We will also be posting these documents on ourwebsite: http://www.eren.doe.gov/buildings/codes_standardslindex.htm

. Please e-mail any comments that you may have to me at this address, Barbara Twigg @ee.doe.gov by January 24, 2002. We would also be happy to meetwith any ofyou that would like to discuss these issues in greater depth. My phone number is 202/586-8714. Thank you very much foryour continued interest and participation in the dishwasher test procedure rulemaking process. Sincerely,Having published on December 18, 2002, a final rule for dishwashers to improve the reliability oftesting, change the definition ofcompact and standard models, and reduce the number ofuse cycles peryearto 264, the Department ofEnergy is nowworking to develop a newtestprocedure for soil-sensing dishwashers. We received on December 12,2001, a report from Arthur D. Little evaluating available survey data onconsumer dishwasher use. Based onthatreport, we are considering the following elements as part ofa newtestprocedure proposal. Itis anticipated that a Notice ofProposedRulemaking, based on a soiledtest method, will be publishedthis spring. 1. For conventional dishwashers, to maintainthe current clean load test method. 2. For soil-sensing dishwashers, to develop a soil-based test to approximate the varied soil loads that consumers run. Requiring that, • the energy consumptionbe measured for three soil tests ofdecreasing soil level to represent "heavy", "medium", and "light" soil loads, where the level ofsoil is determined from data onconsumer dishwasher use andthe method ofsoiling is**bas~d** onthe AHAM test method. (e.g., simulating a "light" soil load with one AHAM soiledplace setting plus eight cleanplace-settings and 6 clean serving pieces)

• the overall energy consumption value for the dishwasher be obtained by means of a weighted average ofthe three test values, based onthe percentage oftime consumers run "heavy", "medium", and "light" soil loads.

• the EstimatedAnnual Operating Costbe obtained inthe same method as conventional dishwashers

• bothcurrent and future soil-sensing models be tested using the soil-basedtest procedure. 3. Forall dishwashers, to revise the estimated annual dishwasher use based on more recent surveyresults. 4. For all dishwashers, to require the measurement ofthe stand-bypower and incorporate this form ofenergy consumption into the annual energy use, ratherthan measuring and reporting stand-bypower as a separate value.